Toronto, March 25, 2008 - Green Shield Canada addresses the Patented Medicine Prices Review Board (PMPRB) regarding drug pricing.
Green Shield Canada was recently given the opportunity to respond to the Patented Medicine Prices Review Board’s (PMPRB) Discussion Paper – Options for possible Changes to the Patented Medicines Regulations, 1994 and the Excessive Price Guidelines. We feel strongly that the PMPRB needs to hear concerns voiced from the private sector with regards to drug pricing. Our positions on the proposals are summarized as follows:
- All changes made to the Patented Medicines Regulations 1994 should recognize the Canadian market which is approximately 60% private and 40% public. Access to non-excessive prices for employer-sponsored drug insurance plans and for those individuals with no coverage is a fundamental aspect of the PMPRB mandate.
- Green Shield Canada believes in a transparent pricing system and recommends that the PMPRB should make the average transaction price (ATP), or the maximum non-excessive (MNE) prices, publicly available. Publication of the ATP fulfills a role that cannot be played by others such as private sector marketing companies and better complies with achieving the roles of the Board.
- Mechanisms are needed to ensure that the price of a costly drug introduced for a rare disease does not automatically become the price when the drug is approved for use for more common diseases.
- Benefits, such as free goods, need to be considered when calculating ATPs, and we would like to see further work on the mechanisms required to appropriately and consistently incorporate these.
By going to the PMPRB site, you will find the complete submission. We will continue to advocate for keeping drug prices affordable and medications accessible for all Canadians.
Previous submissions Green Shield Canada has responded to numerous PMPRB initiatives in the past, the most recent being a detailed response in August 2006 on the Submission to PMPRB on the Board’s Excessive Price Guidelines. We also responded to the January 2005 Proposed Amendments to the Patented Medicines Regulations and also to the March 2005 Discussion Paper on Price Increases.
Green Shield Canada has advocated for equitable access to affordable health care at the local, provincial and federal level since its inception in 1957. We have taken active roles in public policy discussions and have provided input to many committees, commissions and legislative reviews. We believe that only through active participation will we ensure that all Canadians continue to have access to affordable health care.
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